Loading...
Item P1 PI BOARD OF COUNTY COMMISSIONERS COUNTY of MONROE Mayor Craig Cates,District 1 The Florida Keys Mayor Pro Tern Holly Merrill Raschein,District 5 Michelle Lincoln,District 2 James K.Scholl,District 3 m' David Rice,District 4 Board of County Commissioners Meeting September 20, 2023 Agenda Item Number: P1 2023-1032 BULK ITEM: No DEPARTMENT: County Attorney TIME APPROXIMATE: STAFF CONTACT: Kelly Dugan N/A AGENDA ITEM WORDING: A Public Hearing to consider approval of an Ordinance amending Section 8-37 of the Monroe County Code of Ordinances regarding a statute of limitations defense against code compliance prosecutions. ITEM BACKGROUND: The Florida Legislature has not enacted a statute of limitations for administrative code enforcement procedures such as those held before the Special Magistrate or Code Board. Florida courts have ruled that the statute of limitations for civil actions found in F.S. 95.11 does not apply to such administrative code enforcement matters though property owners do have the ability to raise the equitable affirmative defense of laches in cases where the passage of time has rendered prosecution unfair. Sarasota County v. National City Bank of Cleveland, Ohio, 902 So.2d 233 (Fla. 2d DCA 2005). The laches defense is often confused with a "statute of limitations". "Laches"is the argument a property owner can make that the County has exercised unreasonable delay in bringing a code enforcement case resulting in unfair prejudice to the owner. A statute of limitations on the other hand makes a violation of law immune from code compliance after an arbitrary amount of time elapses regardless of the facts or details of the violation, the seriousness of the violation, and/or the importance of curing the violation. Nevertheless, Monroe County is the only county or municipality- including Key West, Marathon, Islamorada, KCB, and Layton - in the state of Florida that has an ordinance creating a statute of limitations defense against code violations. This ordinance has existed in some form for over 30 years giving property owners in unincorporated portions of the Florida Keys Area of Critical State Concern a way to evade enforcement of laws designed to protect the resources within the FKACSC. That defense exists nowhere else in the Keys or the rest of the State. As it stands now, the current ordinance includes express exceptions to the 4 year statute of limitations defense for two types of flood violations and unsafe structures. The Code Compliance Special Magistrate in Code Compliance Case No. CE20070012 held that, "under section 8-37(a), the limitations period must be measured from the alleged violator's failure to satisfy a 4064 continuing duty" to obtain an after-the-fact permit. A local court conducting limited appellate review overruled the Special Magistrate's decision in a November 18, 2022, opinion in Case No. 21-AP-08-P (the"Stone" opinion), thus preventing prosecution of code violations based on the failure to satisfy a continuing duty to obtain an after-the-fact permit. The Stone decision prohibits the Code Compliance Department from bringing cases against the owners of properties where violations have been hidden or obscured for more than 4 years. A typical type of case where this issue has arisen involves illegal land clearing of sensitive habitat. If left in place, the Stone decision prohibits the County from requiring the restoration of sensitive habitat that was destroyed more than 4 years before the case was initiated. Staff is proposing two alternatives for the Board's consideration. First, one draft ordinance proposes striking Section 8-37 in its entirety, which would promote uniformity with Florida law by making Monroe County consistent with the remaining 66 counties and 411 municipalities in the state, including the five municipalities within the Florida Keys. Alternatively, staff has drafted a second proposed ordinance which would amend Section 8-37 to create an additional exception to the statute of limitations for violations of environmental resource protection regulations or violations presenting an ongoing danger to life or safety. Creating this additional exception to the statute of limitations would allow the County to protect the sensitive Keys environment as well as its residents and visitors from ongoing, unsafe conditions. PREVIOUS RELEVANT BOCC ACTION: At the 04/19/23 BOCC approved permission to advertise a public hearing at the May 17, 2023, BOCC meeting to consider approval of an ordinance amending Section 8-37 of the Monroe County Code of Ordinance regarding a statute of limitations for bringing code compliance prosecutions. At the 05/17/23 BOCC meeting this item was continued via motion to the September 20, 2023, BOCC meeting in Key Largo. Ordinance 027-1991; Ordinance No. 50-2000, Section 3; Ordinance No. 031-2010, Section 3; Ordinance No. 022-2011, Section 2. CONTRACT/AGREEMENT CHANGES: N/A STAFF RECOMMENDATION: Approval. DOCUMENTATION: NOI Code Enforcement SOL.docx Draft Ordinance Striking Section 8-37 of the Monroe County Code.pdf Draft Ordinance Amending Section 8-37 of the Monroe County Code.pdf FINANCIAL IMPACT: 4065 Effective upon filing with the Secretary of State per F.S. 125.66. 4066 NOTICE OF INTENTION TO CONSIDER ADOPTION OF COUNTY ORDINANCE NOTICE IS HEREBY GIVEN TO WHOM IT MAY CONCERN that on May 17,2023,at 9:00 A.M. or as soon thereafter as the matter may be heard,at the Harvey Government Center, 1200 Truman Avenue, Key West, Florida, the Board of County Commissioners of Monroe County, Florida, intends to consider adopting the following ordinance: AN ORDINANCE BY THE MONROE COUNTY BOARD OF COUNTY COMMISSIONERS AMENDING SECTION 8-37 ("PASSAGE OF FOUR YEARS TO PROSECUTIONS") OF THE CODE OF ORDINANCES OF MONROE COUNTY TO CLARIFY THAT CODE COMPLIANCE PROSECUTIONS MUST BE INITIATED WITHIN FOUR YEARS OF THE ACTUAL DISCOVERY OF THE VIOLATION BY THE MONROE COUNTY CODE COMPLIANCE DEPARTMENT; PROVIDING THAT THIS CONSTITUTES AN AFFIRMATIVE DEFENSE THAT THE RESPONDENT CARRIES THE BURDEN TO RAISE AND DISCHARGE BEFORE THE CODE COMPLIANCE SPECIAL MAGISTRATE; TO CLARIFY THAT THIS SECTION DOES NOT APPLY TO PROSECUTION(S) BASED UPON FAILURE TO OBTAIN A PERMIT; TO CLARIFY THAT WORK WITHOUT A PERMIT, SUCH AS DEVELOPMENT (INCLUDING BUT NOT LIMITED TO CONSTRUCTION OR LAND CLEARING), IS CONSIDERED A CONTINUING VIOLATION THAT CONTINUES UNTIL REQUIRED AFTER- THE-FACT PERMIT(S)ARE OBTAINED AND CLOSED OUT. The proposed ordinance may be inspected by the public at the Monroe County website by viewing the agenda packet for the May 17, 2023 meeting, which will be posted beginning on May 5, 2023 at: 0t:;;0..ec0u;r;tytl xclx; Y� cx � t The ordinance may also be viewed at the Monroe County Attorney's office at 1111 12th St. Ste. 408 Key West, FL 33040. The public can participate in the May 17, 2023 meeting of the Board of County Commissioners of Monroe County, FL by attending in person or via Zoom. The Zoom link can be found in the agenda at j!j,.:,//u,�1, ,��„ar°o�",t;,,ol,�„ ,; ;,,a°, ,ll,1„ ,a`, u 1J„ „ J , „��„lt.as. . ADA ASSISTANCE: If you are a person with a disability who needs special accommodations in order to participate in this proceeding,please contact the County Administrator's Office,by phoning(305)292- 4441, between the hours of 8:30a.m.-5:06p.m.,prior to the scheduled meeting; if you are hearing or voice-impaired, call "711': Live Closed-Captioning is available via our web portal @ ( ti: y, for meetings of the Monroe County Board of County Commissioners. Dated at Key West, Florida, this 21st day of April, 2023. (SEAL) KEVIN MADOK, Clerk of the Circuit Court and Ex Officio Clerk of the Board of County Commissioners of Monroe County, Florida 4067 Publication Dates: Keys Citizen(Wed.)4/26/2023 Keys Weekly(Thur.)4/27/2023 News Barometer(Fri.) 4/28/2023 4068 MONROE COUNTY, FLORIDA MONROE COUNTY BOARD OF COUNTY COMMISSIONERS ORDINANCE NO. -2023 AN ORDINANCE BY THE MONROE COUNTY BOARD OF COUNTY COMMISSIONERS STRIKING SECTION 8-37 ("PASSAGE OF FOUR YEARS TO PROSECUTIONS") OF THE CODE OF ORDINANCES OF MONROE COUNTY; PROVIDING FOR SEVERABILITY, AN EFFECTIVE DATE,AND INTER ALIA RULES OF CONSTRUCTION. WHEREAS, the Monroe County Board of County Commissioners (hereinafter "BOCC" or"Board")constitutes the local legislature of unincorporated Monroe County,Florida,and Article VIII, Section 1, of the Florida Constitution, provides that the Board is the governing body of Monroe County with powers of self-government as provided by general or special law; and WHEREAS, certain of those powers have been enumerated in Section 125.01(1), Florida Statutes,and include: (1) The power to adopt ordinances and resolutions necessary for the exercise of its powers and prescribe fines and penalties for the violation of ordinances in accordance with law; and(2) The power to perform any other acts not inconsistent with law; and WHEREAS, Section 125.01(3), Florida Statutes, provides that the enumeration of all powers in Section 125.01,Florida Statutes, are deemed to incorporate all implied powers necessary or incident to carrying out such powers enumerated and further provides that the provisions of Section 125.01, Florida Statutes, shall be liberally construed in order to effectively carry out the purposes of Florida Statutes Section 125.01 and to secure for counties the broad exercise of home rule powers; and WHEREAS, the Board therefore finds and concludes that unpermitted work and development in the unincorporated Florida Keys constitutes a harm to public health, safety, and welfare; and WHEREAS, the Board therefore finds and concludes that the prosecution of unpermitted work and development in the unincorporated Florida Keys which remains unpermitted and/or that remains without the required approved, passed inspection(s), constitutes a continuing harm to the public health, safety, and welfare, and must not be judicially declared to be time-barred; and WHEREAS, the Code Compliance Special Magistrate in Code Compliance Case No. CE20070012 held that, "under section 8-37(a), the limitations period must be measured from the alleged violator's failure to satisfy a continuing duty"to obtain an after-the-fact permit; and WHEREAS a local court conducting limited appellate review recently overruled the Special Magistrate's decision in a November 18, 2022, opinion in Case No. 21-AP-08-P (the "Stone" opinion); and Page 1 of 4 4069 WHEREAS, the statute of limitations established by Section 8-37 is inconsistent with every other local county and municipality in the State of Florida, none of which have a statute of limitations for code enforcement; and WHEREAS, as the Board seeks to make unincorporated Monroe County consistent with the rest of the State. NOW THEREFORE, BE IT ORDAINED BY THE BOARD OF COUNTY COMMISSIONERS OF MONROE COUNTY, FLORIDA, THAT: Section 1. - Recitals and Legislative Intent. The foregoing recitals, findings of fact, statements of legislative intent, and conclusions of law are true and correct and are hereby incorporated as if fully stated herein. Section 2. -Amendment. Section 8-37 of Chapter 8, Article H, of the Code of Ordinances of Monroe County is hereby amended as follows (deletions are stricken through; additions are underlined): (a) All pr-eseetAiens before t4e eede eemplia*ee speeial fnagist+ate shall be initiated within fee-- years of t e eeetifFenee of t e event eemplainedofor- be fq-eve- t,.,.-.a For- tl.o dep%nftmeiit. EZ*eept, however-, tb..,t t is section shall of bar- t e initiatiell of (1) The tinlawftil eenstmetion of a stmettir-e below t4e base flood elevation or- t . . - ii sta*dar-ds of tise of a below base flood elevation stmettir-e as etAlined i • • (c) storage area, shall be diseentintied a*d shall not be enter-ed 44- — --ved after- t4e in a paFtietilar- RV park, et4er- than in a design4ed storage area, Page 2 of 4 4070 shall be eensider-ed a new viel4ien. Pr-evietis leases or- agr-eefnent for- eeetipa-ney or- effective doe oft e . roan ee f of whieh t is seetio is derive Section 3. —Construction. The interpretation of this ordinance, and all provisions of the Monroe County Codes, Comprehensive Plan, floodplain management regulations, and Florida Building Code whose interpretation arises out of, relates to, or are interpreted in connection with this ordinance, these being necessary for the health, safety, and welfare of the residents of and visitors to Monroe County, shall be liberally construed to effectuate the public purpose(s) and policy(ies) hereof, and such interpretations shall be construed in favor of the Monroe County BOCC, and such interpretation shall be entitled to great weight in adversarial administrative proceedings, at trial, and on appeal. Section 4. — Severability, Partial Invalidity, and Survival of Provisions. If any provision of this ordinance, or any section, subsection, or part or portion thereof, is held to be invalid or unenforceable by any administrative hearing officer or court of competent jurisdiction, the invalidity or unenforceability of such provision, or any part or portion thereof, shall neither limit nor impair the operation, enforceability, or validity of any other provision of this ordinance, or any remaining section(s), subsection(s), part(s), or portion(s) thereof. All other provisions thereof shall continue unimpaired in full force and effect. Section 5. —Repeal of Inconsistent Provisions. All ordinances or parts of ordinances in conflict with this ordinance are hereby repealed to the extent of said conflict herein. Such repeal shall not repeal the repealing clause of such ordinance or revive any ordinance which has been repealed hereby. Section 6. — Captions and Paragraph Headings. Captions and paragraph headings, where used herein, are inserted for convenience only and are not intended to descriptively limit the scope and intent of the particular paragraph or text to which they refer. Section 7. —Inclusion in the Monroe County Code of Ordinances. The provisions of this ordinance shall be included and incorporated into the Code of Ordinances of Monroe County, Florida, and shall be numbered to conform with the uniform numbering system of the Code. Section 8. —Effective Date. This ordinance shall be filed in the Office of the Secretary of the State of Florida and shall become effective as provided by law. PASSED AND ADOPTED by the Board of County Commissioners of Monroe County, Florida, at a regular meeting held on the day of 2023. Mayor Craig Cates Mayor Pro Tem Holly Merrill Raschein Page 3 of 4 4071 Commissioner James K. Scholl Commissioner David Rice Commissioner Michelle Lincoln (SEAL) BOARD OF COUNTY COMMISSIONERS Attest: KEVIN MADOK, Clerk OF MONROE COUNTY, FLORIDA By: By: As Deputy Clerk Mayor Approved as to form and legal sufficiency: Kelly Dugan,Assistant County Attorney Page 4 of 4 4072 MONROE COUNTY, FLORIDA MONROE COUNTY BOARD OF COUNTY COMMISSIONERS ORDINANCE NO. -2023 AN ORDINANCE BY THE MONROE COUNTY BOARD OF COUNTY COMMISSIONERS AMENDING SECTION 8-37 ("PASSAGE OF FOUR YEARS TO PROSECUTIONS") OF THE CODE OF ORDINANCES OF MONROE COUNTY TO CREATE AN EXCEPTION FOR VIOLATIONS OF ENVIRONMENTAL RESOURCE PROTECTION REGULATIONS OR VIOLATIONS PRESENTING AN ONGOING DANGER TO LIFE OR SAFETY; PROVIDING FOR SEVERABILITY, AN EFFECTIVE DATE, AND INTER ALIA RULES OF CONSTRUCTION. WHEREAS, the Monroe County Board of County Commissioners (hereinafter "BOCC" or"Board")constitutes the local legislature of unincorporated Monroe County,Florida,and Article V111, Section 1, of the Florida Constitution, provides that the Board is the governing body of Monroe County with powers of self-government as provided by general or special law; and WHEREAS, certain of those powers have been enumerated in Section 125.01(1), Florida Statutes,and include: (1) The power to adopt ordinances and resolutions necessary for the exercise of its powers and prescribe fines and penalties for the violation of ordinances in accordance with law; and(2) The power to perform any other acts not inconsistent with law; and WHEREAS, Section 125.01(3), Florida Statutes, provides that the enumeration of all powers in Section 125.01,Florida Statutes,are deemed to incorporate all implied powers necessary or incident to carrying out such powers enumerated and further provides that the provisions of Section 125.01, Florida Statutes, shall be liberally construed in order to effectively carry out the purposes of Florida Statutes Section 125.01 and to secure for counties the broad exercise of home rule powers; and WHEREAS, Monroe County is part of the Florida Keys Area of Critical State Concern, intended to protect environmental or natural resources of regional or statewide importance, and Monroe County contains one of the most ecologically diverse ecosystems in the United States, which is home to over 30 species of threatened and endangered species; and WHEREAS, the Board therefore finds and concludes that regulations protecting the environment of the unincorporated Florida Keys should be enforced; and WHEREAS,the Board therefore finds and concludes that the prosecution of violations of such regulations prevent a continuing harm to the Florida Keys environment as well as to public health, safety, and welfare, and must not be judicially declared to be time-barred; and WHEREAS,the Board finds that violations presenting an ongoing danger to life or safety should be enforced in order to protect the residents and visitors to Monroe County, and must not be judicially declared to be time-barred; and Page 1 of 4 4073 WHEREAS, the Code Compliance Special Magistrate in Code Compliance Case No. CE20070012 held that, "under section 8-37(a), the limitations period must be measured from the alleged violator's failure to satisfy a continuing duty"to obtain an after-the-fact permit; and WHEREAS a local court conducting limited appellate review recently overruled the Special Magistrate's decision in a November 18, 2022, opinion in Case No. 21-AP-08-P (the "Stone" opinion); and WHEREAS, Section 8-37 contains exceptions for "(1) The unlawful construction of a structure below the base flood elevation level or the minimum standards of use of a below base flood elevation structure as outlined in 44 CFR [and] (2) Determination by the building official or his/her authorized designee of an unsafe building, structure or system as provided in Chapter 6, Section 6-27 of the Code." WHEREAS, the Board seeks to establish an additional exception so that a violation of an environmental resource protection regulation or a violation presenting an ongoing danger to life or safety are not barred by the statute of limitations. WHEREAS, the Board seeks to clarify that the statute of limitations is an affirmative defense, and the burden is on the respondent. NOW THEREFORE, BE IT ORDAINED BY THE BOARD OF COUNTY COMMISSIONERS OF MONROE COUNTY, FLORIDA, THAT: Section 1. — Recitals and Legislative Intent. The foregoing recitals, findings of fact, statements of legislative intent, and conclusions of law are true and correct and are hereby incorporated as if fully stated herein. Section 2. —Amendment. Section 8-37 of Chapter 8, Article 11, of the Code of Ordinances of Monroe County is hereby amended as follows (deletions are stricken through; additions are underlined): Sec. 8-37. —Passage of four years to prosecutions. (a) All prosecutions before the code compliance special magistrate shall be initiated within four years of the occurrence of the event complained of or be forever barred. For the purpose of this section, the term "initiated" means the filing of a notice of violation; depaAme* . This section may only be raised as an affirmative defense in a quasi- judicial code compliance prosecution before the code compliance special magistrate and the burden of proving this affirmative defense is upon the respondent. Except, however, that this section shall not bar toe i*4i +ie of a r etiee 4 a prosecution before the code compliance special magistrate based on the following: Page 2 of 4 4074 (1) The unlawful construction of a structure below the base flood elevation or the minimum standards of use of a below base flood elevation structure as outlined in 44 CFR. (2) Determination by the building official or his/her authorized designee of an unsafe building, structure or system as provided in Chapter 6., Section 6-27 of the Code. (3) A violation of an environmental resource protection regulation or a violation presenting an on _going danger to life or safety. Under this subsection "environmental resource protection regulation" shall mean a law or regulation relating to natural resources,native upland vegetation and/or habitat, land clearing, trenching,fill or filling,resource exploration and/or extraction, clearing allowances and/or limits, environmental design criteria, landscaping, open space, invasive exotics, bufferyards, stormwater, wetlands, wastewater, solid waste, or plants or animals protected or listed as threatened or endangered by Monroe County, the State of Florida, and/or the federal government. (b) After the effective date of the ordinance from which this section is originally derived, any violation of this section, the vacation rental ordinance, a special vacation rental permit or permit conditions, shall be considered a new violation. Previous vacation rental leases or uses or the failure to bring enforcement against vacation rental violations pre-dating this section shall not act as laches or a bar to enforcement actions brought for new violations occurring after the effective date of the ordinance from which this section is derived. (c) Occupancy agreements for RV spaces for a period of six months or more in duration by an individual RV owner within a particular RV park, other than in a designated storage area, shall be discontinued and shall not be entered into or renewed after the effective date of the ordinance from which this section is originally derived. Each lease, sublease, assignment or other occupancy agreement for RV spaces of six months or more in duration in a particular RV park, other than in a designated storage area, shall be considered a new violation. Previous leases or agreement for occupancy or storage of recreation vehicles or RV spaces within a particular RV park, other than for storage in a designated area, shall be discontinued and not be renewed, extended or act as laches or bar enforcement actions brought for new violations occurring after the effective date of the ordinance from which this section is derived. Section 3. —Construction. The interpretation of this ordinance, and all provisions of the Monroe County Codes, Comprehensive Plan, floodplain management regulations, and Florida Building Code whose interpretation arises out of, relates to, or are interpreted in connection with this ordinance, these being necessary for the health, safety, and welfare of the residents of and visitors to Monroe County, shall be liberally construed to effectuate the public purpose(s) and policy(ies) hereof, and such interpretations shall be construed in favor of the Monroe County BOCC, and such interpretation shall be entitled to great weight in adversarial administrative proceedings, at trial, and on appeal. Page 3 of 4 4075 Section 4. — Severability, Partial Invalidity, and Survival of Provisions. If any provision of this ordinance, or any section, subsection, or part or portion thereof, is held to be invalid or unenforceable by any administrative hearing officer or court of competent jurisdiction, the invalidity or unenforceability of such provision, or any part or portion thereof, shall neither limit nor impair the operation, enforceability, or validity of any other provision of this ordinance, or any remaining section(s), subsection(s), part(s), or portion(s) thereof. All other provisions thereof shall continue unimpaired in full force and effect. Section 5. —Repeal of Inconsistent Provisions. All ordinances or parts of ordinances in conflict with this ordinance are hereby repealed to the extent of said conflict herein. Such repeal shall not repeal the repealing clause of such ordinance or revive any ordinance which has been repealed hereby. Section 6. — Captions and Paragraph Headings. Captions and paragraph headings, where used herein, are inserted for convenience only and are not intended to descriptively limit the scope and intent of the particular paragraph or text to which they refer. Section 7. —Inclusion in the Monroe County Code of Ordinances. The provisions of this ordinance shall be included and incorporated into the Code of Ordinances of Monroe County, Florida, and shall be numbered to conform with the uniform numbering system of the Code. Section 8. —Effective Date. This ordinance shall be filed in the Office of the Secretary of the State of Florida and shall become effective as provided by law. PASSED AND ADOPTED by the Board of County Commissioners of Monroe County, Florida, at a regular meeting held on the day of 2023. Mayor Craig Cates Mayor Pro Tem Holly Merrill Raschein Commissioner James K. Scholl Commissioner David Rice Commissioner Michelle Lincoln (SEAL) BOARD OF COUNTY COMMISSIONERS Attest: KEVIN MADOK, Clerk OF MONROE COUNTY, FLORIDA By: By: As Deputy Clerk Mayor Approved as to form and legal sufficiency: Kelly Dugan,Assistant County Attorney Page 4 of 4 4076 Comments against proposed ordinances changing section 8-37, Monroe County Code. BOCC Agenda Item P1, September 20, 2023 The ubiquitous wisdom "If it ain't broke, don't fix it" applies to section 8-37, Monroe County Code, which is a 4-year statute of limitation on code compliance prosecutions. The purposes of statutes of limitations have been well explained by the Florida Supreme Court. "...[S]tatutes of limitation afford parties needed protection against the necessity of defending claims which, because of their antiquity, would place the defendant at a grave disadvantage. In such cases how resolutely unfair it would be to award one who has willfully or carelessly slept on his legal rights an opportunity to enforce an unfresh claim against a party who is left to shield himself from liability with nothing more than tattered or faded memories, misplaced or discarded records, and missing or deceased witnesses." Allie v. Ionata, 503 So.2d 1237 (Fla. 1987). "Statutes of limitations are designed to protect defendants from unusually long delays in the filing of lawsuits and to prevent prejudice to defendants from the unexpected enforcement of stale claims. See Totura 8v Co. v. Williams, 754 So.2d 671, 681 (F1a.2000) (explaining that the purpose of statutes of limitations is "to promote justice by preventing surprises through the revival of claims that have been allowed to slumber until evidence has been lost, memories have faded, and witnesses have disappeared." Caduceus Props., LLC v. Graney, 137 So. 3d 987 (Fla. 2014) Page 1 of 2 The proposed changes to section 8-37 are contrary to the purposes and underlying policies favoring statutes of limitation. Eliminating section 8-37 will lead to an increase in stale code claims and prejudice property owners from having an affirmative defense against such stale claims. The purpose of section 8-37 is to promote timely prosecution of code claims by the County, not to encourage people to violate the code. There is no evidence that the 4-year bar has been abused by property owners as claimed by staff. Rather, the limitation defense protects unsuspecting and innocent property owners from unfair surprise and prosecution of alleged code violations which may or may not have merit. The lack of definition for the term "ongoing danger to life safety" will result in needless litigation. The existing section 8-37 is not broken and should be left as-is. Van D. Fischer, Esq. VDF LAW, PLLC 626 Josephine Parker Dr. #205 Key West, FL 33040 305-849-3893 Page 2 of 2